August 6, 2020
I am writing today in partial support of the purposed rule change to amend the regulatory filing from $100MM to $3.5B. While I can understand the justification for proportionally raising the threshold to an equivalent $100MM from the decade which the rule was enacted, I believe that $3.5B is too high and an obscure threshold. I would recommend changing the filing requirement to a flat $1B. It is a round number that even with market fluctuation you have a generally good idea if you are at or above that threshold whereas $3.5B is harder to have an idea about.
I am responsible for gathering all the data for my firms 13f filings and I can tell you that it is not as easy as clicking a button as most people think. If I had to put an conservative estimate on the time it takes to gather the information, pull out pertain data and then compare to the SECs 13f report (which does not help that it is in PDF form and cannot be export to excel), I would say I am looking at 3 to 4 hours a quarter doing this. That may not sound like a lot to a retail investor or anybody not in the business, but those are hours that cannot be gained back.
In summary I support the purposed rule change albeit not to $3.5B but a smaller, rounder threshold such as $1B. There are other ways for people to gather information about who is holding a 13f eligible security, especially if that firm is a larger institution. The $100 MM is an operational burden for smaller to mid-sized firms to have to spend precious hours every quarter data gathering and filing. The change to a higher dollar will not drastically change the transparency of larger institutions who have to file but will give much needed time back to small and mid-sized firms who would now fall below the threshold.
These are my opinions and do not represent the views of my employer(s), client(s), or other institutions.